EPA’s National Emission Standards for Hazardous Air Pollutants and New Source Performance Standards for the Petroleum Refinery Sector: Technical Corrections

EPA's National Emission Standards for Hazardous Air Pollutants and New Source
Performance Standards for the Petroleum Refinery Sector: Technical
Corrections
• On March 19, 2018, the U.S. Environmental Protection Agency (EPA) proposed amendments
to the National Emission Standards for Hazardous Air Pollutants (NESHAP) Refinery MACT 1
and Refinery MACT 2 regulations to clarify the requirements of these rules and to make
technical corrections and revisions to requirements for work practice standards,
recordkeeping and reporting.
• The proposed amendments pertain to maintenance venting requirements and associated
recordkeeping and reporting; operating requirements for steam-assisted flares; fenceline
monitor placement; provisions that apply when the water-over approach is used to meet
the delayed coker vent standards; and the types of pressure relief devices (PRDs) subject to
the PRD atmospheric release work practice standards. The proposal also includes proposed
amendments to make the rule requirements more clear and consistent.
• These revisions are being proposed in order to remove uncertainty associated with the
implementation of the final rule amendments and to simplify compliance. Addressing
implementation issues related to electronic reporting requirements are also included.
• This proposal contains corrections of typographical errors and cross-referencing errors
where the rules cite incorrect sections and/or paragraphs. This action also proposes
technical corrections for the new source performance standard (NSPS) for petroleum
refineries, which are in response to petitions for reconsideration and requests for
clarification on various aspects of the 2015 Refinery Final Rule Amendments.
Burden reductions
• This proposed action would impose no additional costs to industry and would reduce costs
associated with rule compliance. It would not affect emission reductions projected for the
final rule.
• The total cost savings from implementing these proposed amendments is expected to be
$77 million capital investment and annualized costs of $12 million. Most of the cost
reduction is attributable to the proposed amendments for maintenance vent requirements,
recordkeeping and reporting.
Background
• Published on December 1, 2015, the Refinery Sector Rule became effective on February 1,
2016. The EPA received three separate petitions for reconsideration.
• On July 1, 2016, the EPA issued a final rule that provided more time for refiners to comply
with some of the new requirements of the 2015 rule for maintenance activities associated
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with process vents and for periods of startup and shutdown associated with fluidized
catalytic cracking units and sulfur recovery units. The EPA also finalized technical corrections
and clarifications to the final rules promulgated on December 1, 2015, including the
Refinery MACT standards and the (NSPS) amendments.
•	On October 18, 2016, the EPA proposed two minor clarifying amendments and provided
opportunity for public comment on several issues identified in the two February 1, 2016
petitions, including: 1) the work practice standards for PRDs; (2) the work practice
standards for emergency flaring events; (3) the assessment of risk as modified based on
implementation of these PRD and emergency flaring work practice standards; (4) the
alternative work practice standards for DCUs employing the water overflow design; and (5)
the provision allowing refineries to reduce the frequency of fenceline monitoring at
sampling locations that consistently record benzene concentrations below 0.9 micrograms
per cubic meter.
How to Comment
•	EPA will take public comment on the notice for 45 days after they are published in the
Federal Register. There are multiple ways to submit written comments. Please use one of
the methods below to ensure your comments are the methods below to ensure EPA
receives your comments.
•	Comments, identified by Docket ID No. EPA-HQ-OAR-2010-0682, may be submitted by one
of the following methods:
o Federal eRulemaking Portal: http://www.regulations.gov. Follow the online
instructions for submitting comments. Once submitted, comments cannot be edited
or withdrawn. The EPA may publish any comment received to its public docket. Do
not submit electronically any information you consider to be Confidential Business
Information (CBI) or other information whose disclosure is restricted by statute,
o Email: A-and-R-Docket@epa.gov. Include Docket ID No. EPA-HQ-OAR-2010-0682 and
in the subject line of the message,
o Fax: (202) 566-9744.
o Mail: Environmental Protection Agency, EPA Docket Center (EPA/DC), Mail Code
28221T, Attention: Docket ID No. EPA-HQ-OAR-2010-0682, 1200 Pennsylvania
Avenue, NW, Washington, D.C. 20460. Please include a total of two copies. In
addition, please mail a copy of your comments on the information collection
provisions to the Office of Information and Regulatory Affairs, Office of
Management and Budget (OMB), Attn: Desk Officer for EPA, 725 17th Street, NW,
Washington, D.C. 20503.
o Hand/Courier Delivery: EPA Docket Center, Room 3334, EPA WJC West Building,
1301 Constitution Avenue, NW, Washington, D.C. 20004. Such deliveries are only
accepted during the Docket's normal hours of operation, and special arrangements
should be made for deliveries of boxed information.
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• For tips on submitting comments, see https://www.epa.gov/dockets/commentine-epa-
dockets.
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